Privacy

CELOTTI AUSTRALIA PRIVACY POLICY v2 (2013)

Adherence to RCSA Code for Professional Conduct

As a Member of RCSA Limited we must take reasonable steps to maintain the confidentiality and privacy of information obtained in the course of our professional practice.

We must also take reasonable steps to ascertain the extent to which any information we collect may be confidential.

RCSA administers Disciplinary & Dispute Resolution Procedures that you may have access to if you consider that we have breached the RCSA Code for Professional Conduct. Visit www.rcsa.com.au for information.

Privacy Principles

For Information subject to Australian law, the National Privacy Principles established by the Privacy Act 1988 (C’th) apply to Celotti Australia.

How to contact us

If you wish to contact us about your personal information you should contact Suzie Celotti, Managing Director, on 0402 126 535 during normal office hours which are 8:00am – 5:00pm Monday to Friday.

If you need to contact us about your personal or sensitive information urgently outside normal office hours you should contact Suzie Celotti, Managing Director.

Necessary

We will only collect information that is necessary for the proper performance of our tasks or functions.

We do not collect personal information just because we think it could be useful at some future stage if we have no present need for it.

We do not routinely conduct criminal history checks and only do so in order to obtain relevant criminal history with regard to particular jobs you are offered or for which you are shortlisted.

We do not collect or use personal information for the purposes of unlawful discrimination.

We may decline to collect unsolicited personal information from or about you and may take such measures as we think appropriate to purge it from our systems.

Type of Personal Information Held

Personal information that we collect and hold usually falls into the following categories:

Candidate information submitted and obtained from the candidate and other sources in connection with applications for work;

Work performance information;

Information about incidents in the workplace;

Staff information;

Information submitted and obtained in relation to absences from work due to leave, illness or other causes; and

Information obtained to assist in managing client and business relationships.

How your information will be collected

Personal information will be collected from you directly when you fill out and submit one of our application forms or any other information in connection with your application to us for work.

Personal information is also collected when:

we receive or give any reference about you;

we receive results of inquiries that we might make of your former employers, work colleagues, professional associations or registration body;

we receive the results of any competency or medical test;

we receive performance feedback (whether positive or negative);

we receive any complaint from or about you in the workplace;

we receive any information about a workplace accident in which you are involved;

we receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you are involved;

you provide us with any additional information about you; and

electronically through our telecommunications and technology systems – see the section in this policy on electronic transactions.

Purposes for which we hold personal information

We primarily hold personal information for the following:

Employment placement operations;

Recruitment;

Staff management;

Training;

Risk management;

Client and business relationship management;

Marketing services to you; but only where this is permitted and whilst you are registered with us; and

Statistical purposes and statutory compliance requirements.

Disclosures

We may disclose your personal information for any of the purposes for which it is primarily held or for a related purpose where lawfully permitted.

We may disclose your personal information where we are under a legal duty to do so, including circumstances where we are under a contractual or lawful duty of care to disclose information.

We do not share personal information about you with government agencies, organisations or anyone else unless one of the following applies:

You have consented;

You would reasonably expect, or have been told, that information of that kind is usually passed to those individuals, bodies or agencies;

it is required or authorised by law;

it will prevent or lessen a serious and imminent threat to somebody’s life or health;

the disclosure is reasonably necessary for the enforcement of the criminal law or of a law imposing a pecuniary penalty, or for the protection of public revenue.

Outsourced Service Suppliers

We outsource a number of services to contracted service suppliers (CSPs) from time to time. Our CSPs may see some of your personal information. Typically our CSPs would include:

I.T. contractors and database designers and service internet service suppliers, some of whom may be off shore;

Legal and other professional advisors;

Insurance brokers, loss assessors and underwriters;

Superannuation fund managers; and

Background checking and screening agents.

We take reasonable steps to ensure that terms of service with our CSPs recognise that we are bound by obligations to protect the privacy of your personal information and that they will not do anything that would cause us to breach those obligations

Direct Marketing

Your personal information may be used for marketing purposes in the following ways:

personal information might be used for marketing purposes directly or by a third party;

customer lists may be obtained from third parties for marketing purposes;

Celotti Australia gives individuals the direct option as to whether or not they wish to receive marketing communications (usually accompanied by a tick box for a “yes” or “no” response).

Celotti Australia complies with the requirements of the anti-spam legislation.

Personal Information Quality

We rely on you to tell us when there are changes to your personal information that we hold about you. This could be e.g. a change of address or employment status.

Children, Minors and Persons under a Legal Disability

Determining the decision-making capabilities of a person who is under a legal disability can be a complex matter, often raising ethical and legal issues.

We endeavor to address each case individually with a view to deciding whether the individual is able to give consent or receive notifications based upon an assessment of whether the individual has sufficient understanding to comprehend the nature and quality of what is being proposed.

In some circumstances, it may be appropriate for a parent, guardian, holder of an enduring power of attorney (or like authority) or next of kin whom to be contacted in any case in which consent is required or notification is to be given and where it is not practicable to obtain it from or give it directly from the individual.

Personal Information Security

We take reasonable steps to destroy or permanently de-identify personal information when it is no longer required for any purpose for which it may be used or disclosed. However it is not always practicable to destroy or de-identify electronic data. Where it is not reasonable to destroy or permanently de-identify personal information in electronic form, we will take reasonable steps to prevent inadvertent access to it.

Photos and Images

We will not request that you supply photographs, scan photo ID, or capture and retain video image data of you in cases where simply sighting photographs or proof of identity documents would be sufficient in the circumstances.

At times video surveillance which operates in or near our premises may capture images of you.

Inquiries and Complaints

You can make further inquiries or complaints about our privacy policies to our Privacy Coordinator whose contact details are:

Other Parties

We cannot guarantee that any recipient of your personal information will protect it to the standard to which it ought to be protected. The costs and difficulties of enforcement of privacy rights in foreign jurisdictions and the impracticability of attempting to enforce such rights in some jurisdictions will mean that in some instances, we will need to seek your consent to disclosure.

Access

Subject to some exceptions that are set out in privacy law, you can gain access to the personal information that we hold about you.

Important exceptions include evaluative opinion material obtained confidentially in the course of our performing reference checks and access that would impact on the privacy rights of other people. We do refuse access if it would breach any confidentiality that attaches to that information or if it would interfere with the privacy rights of other people. In many cases evaluative material contained in references that we obtain will be collected under obligations of confidentiality that we make and which the communicator of that information is entitled to expect will be observed.

If you wish to obtain access to your personal information you should contact our Privacy Coordinator. You will need to be in a position to verify your identity.

We might impose a moderate charge in providing access. Our Privacy Coordinator would discuss these with you.

You should also anticipate that it may take a little time to process your application for access as there may be a need to retrieve information from storage and review information in order to determine what information may be provided. We will generally respond to your request for access within 20 working days.

Electronic Transactions

This section explains how we handle personal information collected from our website www.celotti.com.au and by other technology in the course of electronic transactions.

It is important that you understand that there are risks associated with use of the internet and you should take all appropriate steps to protect your personal information. It might help you to look at:

We do not identify users or their browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the internet service provider’s server logs.

We do not accept responsibility for the privacy policy of any other site to which our site has a hyperlink, and it is advisable to look at the privacy policy of other sites before disclosing personal information.

Cookies

Cookies are uniquely numbered identification numbers like tags which are placed on your browser. By themselves cookies do not identify you personally, but they may link back to a database record about you. If you register on our site we will then link your cookie back to your personal information details.

This site uses cookies to monitor usage of the website, to enable purchases, and to create a personal record of when you visit our website and what pages you view. Cookies are necessary to enable us to plan future website changes and marketing activities, but if you do not wish us to retain any information about your visit to our site you could delete the cookies on your browser and change the settings on your web browser program.

Web Bugs

If we use web bugs we will display a clearly visible icon on the page. The icon will include the name of the company collecting information and will be labelled as a tracking device. The Web bug will be linked to a page disclosing what data is collected, how it is used, and which companies receive the data. Web visitors will be able to opt out of data collection by Web bugs. Web bugs will not be used to collect sensitive information.

Cloud Computing Services

We cannot guarantee that any recipient of your personal information will protect it to the standard to which it ought to be protected. The costs and difficulties of enforcement of privacy rights in foreign jurisdictions or against third parties and the impracticability of attempting to enforce such rights in some jurisdictions will mean that in some instances, we will need to seek your consent to disclosure.

In cases where we use cloud computing services we will take reasonable steps to ensure that:

disclosure of your personal information to the cloud service provider is consistent with our disclosure obligations under the Privacy Principles. This may include ensuring that we have obtained your consent, or that the disclosure is for purposes within your reasonable expectations.

disclosure is consistent with any other legal obligations, such as the restrictions on the disclosure of tax file number information or the disclosure by private employment agencies of work-seeker details;

our Cloud computing services provider’s terms of service recognise that we are bound by obligations to protect the privacy of your personal information and that they will not do anything that would cause us to breach those obligations.

Social Networks and Web Searches

In order to assess your suitability for positions and to assist you to find work, we will need to collect, use and disclose personal information about you. It has become common practice in some places for employment service providers to conduct background checking via social network media sites frequented by candidates.

We will not conduct background checking via social network media sites other than those that you identify and authorise us to check. However we do conduct internet searches using search engines and entering your name and relevant identifying details.

Uploading photographs

Please make sure that you do not upload photographs of any individuals who have not given consent to the display of their photograph. Displaying photographs without that person’s consent may breach privacy laws, and you may be responsible for any legal consequences.

Emails

Our technology systems log emails received and sent and may include voting, and read and receipt notifications to enable tracking.

When your email address is received by us because you send us a message, the email address will only be used or disclosed for the purpose for which you have provided it and it will not be added to a mailing list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.

Call and message logs

Our telephone technology (systems and mobile phones) logs telephone calls and messages received and sent and enables call number display.

When your call number is received by us because you phone us or send us a message, the number will only be used or disclosed for the purpose for which you have provided it and it will not be added to a phone list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.

Teleconferences and Video conferences

Teleconferences and video conferences may be recorded with your consent. In cases where it is proposed that they be recorded, we will tell you first the purpose for which they are to be used and retained.

Database

We use recruiting software and databases to log and record recruitment operations.

Paperless Office

Recognising the environmental advantages and efficiencies it provides, we operate a partially paperless office as a result of which your paper based communications with us may be digitised and retained in digital format, the paper based communications may be culled.

It is therefore important that, except where specifically requested, you do not send us originals of any paper based document and that you retain copies for your own records.

Where we do request original paper based documents we will return them to you once they are no longer required by us for the purpose for which they may be used or disclosed.

Future Changes

This policy may change over time in light of changes to privacy laws, technology and business practice. If you use our website regularly it is important that you check this policy regularly to ensure that you are aware of the extent of any consent, authorisation or permission you might give.